DaQuan R. Johnson v. Lisa Young and Brandon Stewart

Summary

The United States District Court for the District of South Carolina grants summary judgment to Lisa Young and Brandon Stewart in a 42 U.S.C. § 1983 action brought by a civilly committed resident of the South Carolina Sexually Violent Predator Treatment Program. The court rejects claims concerning a temporary finger-food diet, destruction of meals, and forced medication, finding no constitutional violation or sufficient personal involvement by the defendants. The court adopts the magistrate judge’s Report and Recommendation, dismisses the claims with prejudice, and denies the plaintiff’s additional-discovery motions.

Holdings

1. Because Johnson's objections referenced each claim with sufficient specificity, the district court reviewed the objected-to portions de novo and adopted the Report and Recommendation after finding no error.
2. The dietary restriction did not violate Johnson's constitutional rights because he failed to present evidence that the safety-based restriction was a substantial departure from accepted professional judgment, practice, or standards.
3. The temporary delay in providing Johnson a replacement meal did not constitute a sufficiently serious deprivation to support a Fourteenth Amendment deliberate-indifference claim.
4. Johnson's forced-medication claim failed as a matter of law because he did not allege or demonstrate that either defendant personally administered or ordered the medication.
5. Johnson's motions for additional discovery, including requests concerning subpoenas and video evidence, were denied because the requested materials were not dispositive and summary judgment was proper on the existing record.

Questions Presented

1. Whether the district court properly reviewed and adopted the magistrate judge's Report and Recommendation.
2. Whether the finger-food dietary restriction violated Johnson's Fourteenth Amendment due-process rights.
3. Whether the temporary destruction or delay of Johnson's meals constituted an objectively serious deprivation supporting a deliberate-indifference claim.
4. Whether Johnson stated a § 1983 claim for forced medication when he did not allege that either defendant personally administered or ordered the medication.
5. Whether Johnson's motions for additional discovery should be granted.

Disposition

dismissed